Offering/Service

Flameback Capital Private Limited (Flameback) offers an online investment platform through which its clients can invest in proprietary investment model portfolios and model strategies designed and managed by Flameback Capita itself based on algorithms using internal or third-party licensed data. Flameback Capital Private Limited allows clients to invest in these strategies by simultaneously mirroring or replicating the trading activity in a third-party brokerage account owned and operated by the client.

Flameback does not have any relation or affiliation or understanding of sharing of brokerage or referral bonus or any other kind of commission with any brokers on its platform or any other platform such as Smallcase.

Flameback portfolios and strategies can also be replicated on Smallcase (Flameback. Smallcase.com) through the various brokers available on its platform.
Flameback recommends appropriate investment strategies after assessing a client’s investment objective, risk tolerance and other preferences through a questionnaire (see below). Based on the questionnaire, Flameback recommends a suitable investment portfolio or strategy to a client. Investment portfolios are categorized according to low risk to very high risk and client risk tolerance is quantitively assessed through methodology that assigns aggerate score after assigning individual scores to questions pertaining to ability to take risk, willingness to take risk, liquidity requirements and time horizon and other relevant matters. A high aggregate score will mean a client has a high-risk tolerance, our risk tolerance scoring methodology is available here. Our Investment Policy Statement document recommends the appropriate asset allocation mix for a client and we recommend an appropriate investment strategy after considering other factors such as investment amount, objectives, and client preferences.

Clients can also invest in portfolios and strategies with a risk score equivalent to or lower to their personal risk score. Client can independently choose to invest in portfolios are strategies that have a higher risk score than their own personal risk score after they sign a waiver that they can understand the risks of doing so and the perils of taking higher risks than their ability or risk tolerance permits them to.

Clients can update their responses to the risk questionnaire on Flameback Capital website or contacting us to reflect changes in their personal circumstances. Changes to the risk questionnaire responses could result in a change in a client’s risk score and thus the portfolios that a client is able to invest in.

Flameback advisory services are provided to investors who become clients after they sign an investment advisory agreement. Both potential and existing clients are urged to read carefully and consider whether such an agreement is suitable for their personal circumstances.

Clients interested in using Flameback Capital Advisory Services should know Flameback provides its investment advisory services primarily online, although it does make client support staff available for consultation as needed by clients on servicing and investment management issues. Clients should be able and willing to conduct most of their interactions with Flameback using electronic methods. In the Investment Advisory Agreement, they execute with Flameback, Clients agree to receive all documents, notices, and updates electronically by email or through their access to Flameback Capital website accompanied by an email notice.

PAST PERFORMANCE IS NO GUARANTEE OF FUTURE RESULTS. FURTHERMORE, PAST RETURNS MAY REFLECT THE PERFORMANCE OF ASSETS FOR A FINITE TIME, OR DURING A PERIOD OF EXTREME MARKET ACTIVITY. ALL INVESTMENTS INVOLVE RISK AND MAY LOSE MONEY, INCLUDING LOSS OF PRINCIPAL AND A REDUCTION IN EARNINGS. INVESTORS MAY LOSE ALL OR PART OF THEIR INVESTMENTS IN ANY FLAMEBACK PORTFOLIOS OR STRATEGIES.

Flameback uses its best judgment and good faith efforts in rendering services to clients, but it cannot warrant or guarantee any level of account performance, or that any account will be profitable over time. Not every investment decision or recommendation made by Flameback Capital will be profitable. Flameback clients assume all market risk involved in the investment of account assets under the Investment Advisory Agreement and understand that investment advice provided made by Flameback are subject to various market, currency, economic, political, and business risks. There can be no assurance that an investment in one or more Flameback portfolios or strategies or other recommended investment products or any actual performance shown on the Flameback website, or any other electronic or printed material will lead to the same results in the future or perform in any predictable manner. It should not be assumed that investors will experience returns in the future, if any, comparable to those shown or that all Flameback clients experienced such returns.

System response and account access times may vary due to a variety of factors, including trading volumes, market conditions, system performance, and others.

Flameback Suitability Recommendation and Investing

Portfolios and strategies available for investment on the Flameback Capital platform may not be suitable for all investors. Flameback recommends strategies and portfolios to clients it deems suitable based on the objective, risk tolerance, financial situation and preferences based on client’s responses in the questionnaire.

Therefore, the investment advice provides to clients is highly dependent on the accuracy of the information provided to Flameback Capital by its clients. If a client provides inaccurate information, then the quality of advice might be affected. Also, failure by Flameback Capital or clients to regularly update the information to update changes to a client’s financial situation or objectives or preferences might lead the portfolio advice being provided not being entirely suitable to changed circumstances. Flameback Capital will periodically prompt clients to redo the questionnaire to keep track of changes in client’s priorities and circumstances.

The advice that Flameback Capital provides is limited to the responses and information based on the client questionnaire in our website or other platforms. There may be additional information not asked for in our questionnaire that could be important but is not considered in the investment advice provided by Flameback. Also, Flameback recommendations are limited to the investment options provided by Flameback and these options might not be the best option for the client. Also, Flameback does not consider other important considerations such as taxation, retirement planning, financial planning, estate or insurance or other important factors, which affect appropriate investment advice. Clients may choose to contact another financial advisor to discuss additional information or alternative investment options and to get advice on tax planning, estate planning, retirement planning and insurance advice.

Client Account Performance Returns

Past performance is no guarantee of future results.
Periodic and since inception performance returns for portfolios are strategies that are calculated on every trading day and presented after calculation and consideration of dividends, fees, and trading costs.

For client accounts, periodic and since inception returns are updated at the end of the day on every trading day. Performance of client account is calculated on time-weighted basis.

We rely on mathematical formulas, computer programs, and pricing information from third party vendors to provide these returns. Neither Flameback Capital nor any of its data or content providers shall be liable for any errors in the information or any action by you in reliance upon this information.

Model Portfolio and Model Strategy Performance

The performance charts are provided for informational purposes only and should not be used as the basis for making an investment decision.

None of the model portfolio or model strategy information displayed on performance in the Flameback Capital website, app, Smallcase and other material is based on the actual performance of any client account investing in any portfolio

Performance of the Model Portfolio and Model Strategy on each portfolio page is calculated daily on a time-weighted bass and applied retroactively to present.

The Performance graph, statistics, and indicators for each portfolio and strategy on the Flameback’s website and other general content are simulated and does not consider dividends, fees, trading cost and other charges.

Client account performance may differ from the performance of the Model Portfolio’s performance displayed on the public website or other platform. Client’s portfolio may be higher or lower than the model portfolio because of the timing of the investment and the difference in the purchase price between the two accounts. The other reasons why there might be a difference is due to restrictions imposed by the client resulting in a different account holding, investment amount, frequency and size of investments and withdrawals, trading costs, slippage, and corporate actions.

Limitations of Using Model Portfolios

Information on our model portfolio and model strategy performance contains hypothetical data and hence should be considered with caution because:

• Hypothetical performance results have many inherent limitations, some of which are described below. No representation is being made that any account will or is likely to achieve profits or losses similar to those shown.

• In fact, there are frequently sharp differences between hypothetical or simulated model performance results and the actual results subsequently achieved by any particular model portfolio or strategy.

• One of the limitations of hypothetical performance results is that they are generally prepared with the benefit of hindsight.

• Also, model performance and historical backtests might not reflect actual trading environment experience as it does not calculate slippage market impact costs, actual transaction costs etc.

• In addition, hypothetical trading does not involve financial risk, and no hypothetical trading record can completely account for the impact of financial risk in actual trading. For example, the ability to withstand losses or to adhere to a particular portfolio or strategy in spite of trading losses are material points which can also adversely affect actual investment and trading results. There are numerous other factors related to the markets in general or to the implementation of any specific investment portfolio or strategy which cannot be fully accounted for in the preparation of hypothetical performance results and all of which can adversely affect actual trading results.

• This model portfolio performance record is hypothetical, and these individual strategies have not traded together in the manner shown in the model portfolios. Hypothetical performance results have many inherent limitations, some of which are described below.

Trade Execution

Flameback Capital advises clients to replicate or mirror their investment accounts with the recommended model portfolio and strategy. Clients choose the specific portfolios and strategies and may reserve or block the specific investment amounts from being made from their brokerage accounts. While Flameback Capital aims to replicate client portfolios with the model portfolios as close to as possible, it cannot guarantee that it will be able to replicate the portfolios in part or whole and achieve the same performance as the model portfolio and strategy. This is due to number of factors such as:

• Delayed or no authorization by the client to execute trades.

• The timing of the client’s initial investment and subsequent additions and withdrawals to the account.

• Restrictions placed by client or another third party such as a bank or financial institution for trading on client’s investment account.

• Delay in receipt of reception of portfolio data.

• Client actions in their brokerage account such as selling investments purchases on recommendation of Flameback Capital pre-maturely or adding or withdrawing funds without informing Flameback Capital or doing it via Flameback’s process on web application.

• Any corporate action that affects the stock that the client is holding.

• Any disruption to Flameback’s ability to provide investment advice and execute trades on client’s accounts in a timely manner.

Investment Risk Warning

• The value of investments can go down as well as up and, therefore, the value of your portfolio at any given point in time cannot be guaranteed.

• Upon withdrawal or transfer of your portfolio you may not realize the sum originally invested.

• Past performance is not necessarily a guide to future returns.

• The performance of the investments/products may be affected by changes in Government policies, general levels of interest rates and risks associated with trading volumes, liquidity and settlement systems in equity and debt markets.

• Investments in the products which the Clients have opted are subject to wide range of risks which inter alia also include but not limited to economic slowdown, volatility & illiquidity of the stocks, poor corporate performance, economic policies, changes of Government and its policies, acts of God, acts of war, civil disturbance, sovereign action and /or such other acts/ circumstance beyond the control of Investment Advisor or any of its Associates.

• The names of the products/nature of investments do not in any manner indicate their prospects or returns. The performance in the equity may be adversely affected by the performance of individual companies, changes in the marketplace and industry specific and macro-economic factors.

• Investments in debt instruments and other fixed income securities are subject to default risk, liquidity risk and interest rate risk. Interest rate risk results from changes in demand and supply for money and other macroeconomic factors and creates price changes in the value of the debt instruments.

• Investments in Securities are subject to market risk and other risks and there is no assurance or guarantee that the objectives of the Trading Strategy Strategies will be achieved.

• Flameback Capital is only the name of the Firm and does not in any manner indicate either the quality of the advice under the service or its prospects and returns.

• ‘Trading Strategy’ or use of the word “Quant Equity, ‘Rapidfire’ or any other word used to brand or name a service, product or research developed by Flameback Capital or its partner is only is only a name or work of branding and does not indicate quality or advice or its future prospects or return.

• Flameback Capital is not responsible or liable for any loss or shortfall resulting from the information provided or operation of the Services.

• Clients of any of Flameback Capital’s product are not being offered any guaranteed/assured returns.

• Clients shall understand that the statements/presentation cannot disclose all the risks and characteristics.

• Back-tested performance is provided for informational purposes only to indicate historical performance had Flameback Strategies been available to investors.

• Actual investors may experience different results from the hypothetical results shown.

• There is a potential for loss that is not reflected in the hypothetical information portrayed.

• The hypothetical back-tested performance results shown do not represent the results of actual trading using client assets but were achieved by means of the retroactive application of a model designed with the benefit of hindsight.

• Please consult us or any other RIA if you have any doubts or feel uneasy about investing in volatile assets.

Conflicts of Interest

• Flameback Capital has numerous investment portfolios and strategies and in each of these portfolios and strategy the logic, methodology, approach differs and hence, the investment advice and investment portfolios will also differ. For example, Hypothetical Portfolio A can recommend to purchase a particular security, while at the same time, Hypothetical Portfolio B might recommend to sell the same particular security. This Is because each portfolio or strategy is different.

• All investment recommendations provided by Flameback Capital are based on the underlying algorithm or investment model or due to an action initiated by the client.

• Other client’s investment accounts and funds advise or managed by Flameback Capital directly or indirectly might have contrary investment positions than advice by Flameback Capital to clients through a particular investment portfolio. However, these are investment positions based on recommendations of another portfolio or strategy.

• The proprietary investment accounts of Flameback Capital and its subsidiaries and affiliates are used mainly to test investment strategies or the functioning of our technology capabilities and troubleshoot issues. These are typically in amounts that are not significant.

• All directors, employees, relatives of employees and directors and other direct affiliates of Flameback Capital are restricted to trade prior to investment and trading recommendations being disseminated to clients. In fact, they are encouraged to invest in passive investment securities.

• However, if any employee, director, relatives of employee and directors and other direct affiliates of Flameback Capital are fee paying clients and have signed the Investment Advisory Agreement, then they are treated on par with any other client.